System and method for conducting an optimized customer identification program

ABSTRACT

A computer-implemented method of compiling a customer information set that complies with regulatory criteria is provided. The method comprises providing an overall question set having a plurality of questions and determining from the overall question set a basic question set, the basic question set including at least one basic question. The method further comprises associating an expected answer with at least one question of the basic question set and providing criteria for modifying the basic question set based on receiving an answer that differs from the expected answer. The method still further comprises optimizing an interactive customer survey with a customer using the overall question set, the basic question set, the expected answer and the criteria for modifying the basic question set.

FIELD OF THE INVENTION

The invention relates generally to business processes involvingcompliance with government regulation and the risks associatedtherewith. More particularly, the invention relates to methods thatenable financial institutions to gather, assess, and aggregate risksassociated with government regulations prior to or simultaneously withthe initiation of an account relationship.

BACKGROUND OF THE INVENTION

In the past decade, there has been an increased interest on the part oflegislatures and regulators in imposing rules upon financialinstitutions (i.e., banks, securities dealers, mutual funds, insuranceproviders and others as defined by the Bank Secrecy Act (USC Title 31))that require these institutions to better identify, investigate, andreport customer and/or transaction activity that is suspicious.Suspicious activities include those involving or relating to theft orfraud. Since the passage of the USA PATRIOT Act in October, 2001,significant emphasis has been placed on a financial institution'scapability to detect and report potential money laundering and terroristfinancing activity.

The USA PATRIOT Act requires financial institutions to meet certainrequirements in order to be compliant with the expectations ofregulators. Among these are the requirements that financial institutionsmust have designated compliance officers focusing on abiding by theregulations set forth in the Bank Secrecy Act; detailed written policiesand procedures for internal controls related to anti-money launderingand terrorist financing activity, and comprehensive anti-moneylaundering and terrorist financing training and education programs. Inaddition, the law requires financial institutions to design andimplement a robust Customer Identification Program (“CIP”).

A financial institution's CIP is required to (1) obtain and verify theidentity of customers; (2) obtain a physical address of customers; (3)obtain a customer's date of birth; and, (4) obtain an identifying numberof a customer such as a Social Security Number of passport number. Fornon-individual customers such as businesses or organizations, thefinancial institution is required to have procedures for ensuring thefull and proper identity of each business or organization, as well asthe identity of the individuals who exercise control over the accountsof the business or organization.

A further requirement of the law is that financial institutions haverisk-based procedures to identify, investigate, and report suspiciousactivity related to potential money laundering and/or terror financing.Regulatory expectations are that financial institutions will have someform of automated information technology system to accomplish this task.The enormity of the task cannot be understated. Many financialinstitutions have hundreds of thousands or even millions of customerswho each day engage in comparable numbers of transactions. Nevertheless,regulatory authorities expect financial institutions to be able tofilter these transactions and identify those that need further review todetermine if they are suspicious. As a result, there is a growing marketfor software products capable of sifting and filtering the millions oftransactions to find those anomalies potentially related to moneylaundering or terror financing. Such products are often referred to as“back end” systems, in that they filter information from transactionsafter they have occurred. In other words, these systems look back onactivities occurring over a period of time in order to identify thosethat are or may be unusual or suspicious.

Back end investigation systems, by definition, cannot assist a financialinstitution in identifying at the start of a business relationship thoseindividuals and/or organizations that are more likely to be involved insuspicious or unusual activity. Accordingly, there is a need for anefficient “front end” system for gathering information and identifyingthose relationships that present a higher than normal risk for moneylaundering or terrorist financing prior to or simultaneous to theopening of an account. Such a system would identify risk, not on pastbehavior, but on certain personal characteristics and anticipatedtransaction characteristics that are known to the regulatory andfinancial industry communities as presenting a higher probability fornon compliance with anti-money laundering laws.

SUMMARY OF THE INVENTION

The invention described herein combines the needs of governmentregulations, business needs (cost/benefit), product requirements(certain products, such as mortgages, have their own regulatoryrequirements for data collection), and customer expectations (time andease of account opening experience) and applies the appropriate businesslogic to assure that the right question is posed to the right person atthe right time.

An illustrative embodiment of the invention accomplishes this through acomputer-implemented method of compiling a customer information set thatcomplies with regulatory criteria. The illustrative method comprisesproviding an overall question set having a plurality of questions anddetermining from the overall question set a basic question set, thebasic question set including at least one basic question. The methodfurther comprises associating an expected answer with at least onequestion of the basic question set and providing criteria for modifyingthe basic question set based on receiving an answer that differs fromthe expected answer. The method still further comprises optimizing aninteractive customer survey with a customer using the overall questionset, the basic question set, the expected answer and the criteria formodifying the basic question set.

BRIEF DESCRIPTION OF THE DRAWINGS

The invention can be more fully understood by reading the followingdetailed description together with the accompanying drawings, in whichlike reference indicators are used to designate like elements, and inwhich:

FIG. 1 is a flowchart of a method for compiling a customer informationset according to an embodiment of the invention;

FIG. 2, which is made up of FIGS. 2 a, 2 b and 2 c, is a chart comparingthe questions that must be asked for two hypothetical customers in orderto comply with certain government regulations;

FIG. 3 is a flowchart of a process of establishing and conducting anautomated, optimized customer information survey according to anembodiment of the invention;

FIG. 4 is a schematic flow diagram illustrating the contributors to anoptimized interactive survey according to embodiments of the invention;

FIG. 5 is a data processing system for compiling a customer informationset according to an embodiment of the invention;

FIG. 6 is a data processing system for compiling a customer informationset according to an embodiment of the invention;

FIG. 7 is a flowchart of a method for compiling a customer informationset according to an embodiment of the invention;

FIG. 8 is a flowchart of a procedure for calculating risk according toan embodiment of the invention;

FIG. 9 is a screen shot of a portion of an exemplary question displayscreen that may be produced and used in methods of the invention;

FIG. 10 is a screen shot of a portion of the question display screen ofFIG. 9 with additional information added;

FIG. 11 is a screen shot of the question display screen of FIG. 9 withportions of the display screen collapsed so that a second portion of thedisplay screen may be viewed;

FIG. 12 is a screen shot of a portion of a modified version of thequestion display screen portion of FIG. 11; and

FIG. 13 is a screen shot of an exemplary question display screen thatmay be produced and used in methods of the invention.

DETAILED DESCRIPTION OF THE INVENTION

Aspects of the systems and methods of various embodiments of theinvention will now be described. As used herein, any term in thesingular may be interpreted to be in the plural, and alternatively, anyterm in the plural may be interpreted to be in the singular.

The systems and methods of the invention provide efficient customerservice oriented tools for assisting financial institutions and otherentities in complying with government regulations. These tools may beused to identify, assess, and quantify the risks associated withestablishing an account or other business relationship with a customerat or before the initiation of that relationship. The systems andmethods of the invention accomplish this through the use of an optimizedcustomer information survey methodology that provides the customerinformation needed to meet the requirements of regulatory agencies,requirements for establishing risk-based profiling procedures, and thebusiness decision-making requirements of the administering financialinstitution and to meet the requirements and expectations of thecustomer. The survey methodology is tailored to minimize the inputrequired for a given customer by continually revising the survey queriesbased on the customer information received. At the same time, riskfactors associated with the information received are aggregated todetermine an overall risk for a particular customer. The methods of theinvention are usable in front-end CIP procedures as well as in processesfor assessing and reassessing risk through the life of acustomer/institution business relationship.

It will be understood that throughout this specification, the term“customer” may apply to any individual, business, organization or otherentity having or seeking to open an account, applying for a loan orotherwise having or seeking to establish a business relationship with afinancial institution or other entity required to comply with governmentregulations relating to, for example, the gathering of customerinformation and/or identification of potentially suspicious activity.

Central to compliance with the regulations arising out of the USAPATRIOT Act, is the need to efficiently determine and quantify the riskassociated with a potential customer. The methods of the invention arepredicated on the concept that every customer has an inherent level ofrisk based on the customer's identifiable personal characteristics andon the customer's historical and projected transactional behavior. Inthe methods of the invention, the overall risk associated with aparticular customer is continually updated as information relating tothese characteristics is received.

Customer information is typically gathered through the use of anapplication form or survey with questions or blanks that may be filledin by the customer or by an employee of the financial institution.Information relating to customer characteristics may be taken from thesurvey and assembled into a customer information set. In some instances,customer information may be taken from data obtained through priordealings with the customer or from sources other than the customer. Itwill be understood that certain customer characteristics may beassociated with higher behavioral uncertainty and, accordingly, higherrisk. Further, some customers will have certain characteristics thatsuggest the need to obtain additional information in order to fullyassess their associated risk and comply with regulatory criteria. Suchadditional information may not be needed for customers not having thosecertain characteristics. For example, if it is determined that acustomer is not a U.S. citizen, a variety of additional informationrelating to the customer's origins and nationality may be required.Thus, the number of characteristics for which information is requiredfor compliance and to assess overall risk may be smaller for aU.S.-based customer than for a non-U.S.-based customer.

Because not all customers have the same characteristics, many will notneed to provide the “additional” information. The result is that theoverall number of questions that may be required for compliance could besignificantly larger than the number of questions actually required fora particular customer.

An aspect of embodiments of the invention is to seek, obtain and processonly the information necessary to meet regulatory criteria for a givencustomer. Accordingly, the invention provides methods of obtainingcustomer information that tailor themselves to the characteristics ofthe customer as information on those characteristics is received. FIG. 1is a high level flow diagram illustrating a conceptual method 100 ofoptimizing a customer information survey in accordance with anembodiment of the invention. The method 100 begins at S105. At S110, abasic question set is established using questions from the universe ofquestions that may be required to gather information for regulatorycompliance. The basic question set includes only those questions towhich all customers will be required to respond, regardless of theirindividual characteristics. At S120, an expected (i.e., probable orlikely) answer is established for each of the basic questions. Theexpected answer may be determined from empirical data and may be basedon a variety of factors including, for example, customer demographics,the nature and location of the financial institution and the types ofproducts and services offered by the financial institution. At S130,one, some or all of the questions from the question set is submitted tothe customer or a customer interviewer to obtain responses, which arereceived at S140. In some instances, the financial institution mayalready have some customer information or may have access to publiclyavailable information. In either case, such information may be used toprovide default answers to some of the survey questions without directcustomer input. The corresponding questions may then be bypassed in thesurvey process or displayed to the customer with the default answers forconfirmation by the customer.

At S150, the answers obtained at S140 are compared to the expectedanswers to determine if any unexpected answers were received. If onlythe expected answers are received, no changes are made to the questionset. If, however, an unexpected answer (i.e., an answer other than theexpected answer) is received, the question set may be revised at S155.This revision would typically involve adding one or more additionalquestions to the question set but, under certain circumstances, couldalso involve removal of questions from the question set. Questions fromthe revised question set are then resubmitted to the customer forresponse. The actions of submitting questions to the customer, receivinganswers, determining if any answers are unexpected and, if necessary,modifying the question set, may be repeated until all the questions inthe question set have been answered. The information taken from theanswers may be stored in a customer information set at S160 and themethod 100 ends at S195.

It should be noted that the effectiveness of the method 100 may beaffected significantly by the way in which the questions are presentedto the customer at S130. For example, if all the basic questions aresubmitted at once, any questions added as a result of unexpected answerswould not sequentially follow the answers that prompted their addition.This may result in a poor experience for the user and the customer. If,on the other hand, the questions are submitted and answered one at atime in a predetermined sequence, additional questions will flownaturally from the questions to which unexpected answers are received.The efficiency of the method 100 may also be affected by the way inwhich the question set is modified. For example, if the information inunexpected answers can be anticipated, the additional questions thatwill need to be asked as a result of such answers may be determined inadvance.

Although not shown in FIG. 1, the method 100 may also include stepsrelating to the computation of risk for the customer being surveyed. Forexample, a basic estimated risk level may be established for a customerwho provides only expected answers. When unexpected answers arereceived, the estimated risk level may be appropriately raised orlowered depending on the answer. As will be discussed in more detailbelow, there are a variety of ways in which an aggregate risk level maybe computed using contributing factors associated with anticipatedanswers to survey questions.

To illustrate the effect of an optimized customer information survey,FIGS. 2 a, 2 b and 2 c show a chart of the questions asked of twohypothetical customers: a first customer who is a U.S.-born U.S. citizenwho wishes to open a checking account; and a second customer who is aforeign born, non-U.S. citizen who wishes to open a joint checkingaccount. The chart shows a list of basic questions in the left-mostcolumn, information relating to the survey questions asked of the firstcustomer in the center portion of the chart and information relating tothe second customer in the right-hand portion of the chart. In each ofthe customer sections, a first column indicates whether the customerprovided an expected answer to the associated question in the left-handcolumn and a second column shows any additional questions that wererequired as a result of unexpected answers. The second column also showsexamples of where answers may prompt a risk value assignment orcalculation.

It can be seen from the comparison chart in FIG. 2 that the firstcustomer provided no unexpected answers. As a result, the first customerneeded to respond to only 36 questions in order to a fully compliantcustomer information set to be constructed. The second customer,however, provided a number of unexpected answers that resulted in theneed for additional questions. The unexpected answer of a country otherthan the U.S. for questions 7 and 9 resulted in the need for theadditional questions shown at 7.1-7.5 and 9.1-9.5. In answer to question12, the second customer indicated he would provide an atypical form ofidentification. This resulted in additional questions at 12.1.Unexpected answers to questions 14, 15, 19, 24, 26, 29 and 36 alsoresulted in additional questions. As a result of the unexpected answers,the second customer was required to answer more than fifty additionalquestions. The second customer's answers also prompted the assignment ofadditional risk values at a number of points in the survey.

Clearly, it is undesirable to force the first customer in the exampleabove to face a survey form or process that included all the questionsasked of the second customer. The above-described method 100 shows how asurvey question set may be modified and optimized based on the answersreceived to avoid this problem. It will be apparent that this simpleapproach can, in theory, be carried out by an interviewer, who simplyevaluates the information he receives in answer to basic questions andstructures subsequent questions based on that information. In this way,the interviewer tailors his session with a customer to minimize thenumber of questions he must ask. The primary advantages of theinvention, however, are realized when the methods of the invention areautomated.

In order to provide a fully compliant automated customer survey, theautomated system must, of course, have access to all possible questionsneeded for compliance. In order for the automated survey to beoptimized, the system must also be provided with a basic initialquestion set and a methodology and criteria for interactively revisingthe question set. FIG. 3 illustrates steps that may be conducted duringthe process of establishing and conducting an automated, optimizedcustomer information survey. At S210, an overall question set includingall possible questions that may be required in order to fully complywith regulatory requirements and with the requirements of the surveyinginstitution in providing service to the customer. At S220, a set ofpossible answers that may be anticipated for various questions areassembled. For example, if the information required is the country ofcitizenship, a set of anticipated answers may include any or all of theestablished nations in the world. Some questions may have anticipatedanswer ranges. For example, a customer may be asked to provide aspecific number for annual income. The anticipated answers for theannual income question, however, may be stated in ranges, one of whichwill include the number provided by any given customer. It will beunderstood that some questions such as those asking for name and addressinformation may not have anticipated answers.

Anticipated answers are significant because they may provide a basis forassigning risk factors to specific characteristics of a customer. AtS230, risk contribution factors are established for the anticipatedanswers. As will be discussed in more detail below, these risk factorsmay be a simple additive value assigned to a particular anticipatedanswer or group of answers or may be a systematic change factor for usein a more complex risk model. A given anticipated answer may or may nothave an impact on the overall risk associated with a customer.

At S240, expected answers to various questions are assembled. Whileanticipated answers are those determined by the administeringinstitution to be possible answers for a given question, an expectedanswer is one determined by the administering institution to be alikely, or the most likely, answer. As discussed above with respect tothe basic survey method 100, expected answers can be used to tailor asurvey to a particular customer. It is this approach that allows thesurvey to be optimized for as customer information is received. It willbe understood that some questions may not have an expected answer. Onlythose questions that will be used to trigger an expansion or contractionof the question set or that may trigger a change to the overall riskcomputation for a customer need be provided with an associated expectedanswer.

Under some circumstances, a particular question may have more than oneexpected answer. For example, a question may ask for a form ofidentification. If there are several likely forms of identification,none of which will result in the need for additional questions or thatwill involve additional risk, an answer of any of these forms ofidentification could be considered an expected answer.

At S250, a basic question set may be established. The basic question setwould consist of some or all of the questions of the overall questionset. The basic question set represents the starting point of the survey.In a preferred approach, the basic question set would comprise thosequestions for which information will be required from all customers. Thebasic question set will include questions with expected answers so thatwhen unexpected answers are received, the basic question set may bemodified to provide appropriate questions based on the unexpectedanswers.

At S260, an automated interactive survey is conducted. The automatedsystem used to conduct the survey may be provided with the overallquestion set, the basic question set, anticipated answers and expectedanswers. The automated system may also be provided with the riskcontribution factors associated with the anticipated answers. Theinformation gathered by the survey may be assembled and stored in theform of a customer information set at S270.

An optimized interactive survey comprising the actions shown in FIG. 3may be conducted as part of a standalone business initiation surveyprocess or as part of an account transaction. Optimized interactivesurveys using the methods of the invention are particularly effective atthe front-end of a business relationship when little or no informationon a particular customer is otherwise available to the administeringinstitution.

A process of establishing and conducting an optimized survey having someor all of the actions of FIG. 3 allows a financial institution to bringits expertise to bear to provide a survey tool that balances the timeconstraints of the customer with regulation compliance and the needs andpolicies of the financial institution. FIG. 4 is a schematicrepresentation of how this balance is accomplished and how the surveymay be used as part of a customer transaction. The methods of theinvention may be carried out at any time during a business relationship,but are particularly useful at or before the opening of an account witha new customer. As shown in FIG. 4, the survey processes of theinvention may be smoothly incorporated into a customer-initiatedtransaction such as the opening of a checking account or an applicationfor a loan.

The automated methods of the invention may be carried out using a dataprocessing system programmed to interactively display questions andreceive answers to and from a customer either through direct interactionwith the customer or through an interviewer or other user. As will bediscussed, if an interviewer or other intermediary is used, thequestions of the survey may or may not be visible to the customer.

FIGS. 5 and 6 illustrate examples of processing systems that may be usedto carry out the methods of the invention. FIG. 5 shows an illustrativestandalone processing system 1000, which may be, for example, a desk topcomputer or work station. The processing system 1000 has a userinterface 1010, a question set optimization module 1020, a riskcomputation module 1030, a data storage module 1040 and a managementmodule 1050. The user interface 1010 may include a display 1012 adaptedfor displaying one or more questions to a user and a user input device1014 adapted for receiving input such as answers or other customerinformation from the user. The question set optimization module 1020 maybe adapted to determine which questions are displayed to the user and itwhat form. The risk computation module 1030 may be adapted to computeincremental and/or aggregate risk factors for a particular customerbased on the answers received from the user. The data storage module1030 may be used to store, among other things, questions, expectedanswers, actual received answers and customer information sets. Themanagement module 1050 may be configured to provide any of variousfunctions for adapting the system 1000 to the needs of a particularfinancial institution.

FIG. 6 shows another illustrative processing system 1100 that may beused to carry out the methods of the invention. The processing system1100 comprises a user station 1102 connected to a central processor orserver 1104 via a network 1106. In this system, the question setoptimization module 1120, risk computation module 1130, data storagemodule 1140 and management module 1150 are part of the central processor1104. The central processor 1104 may also include a communication module1160 adapted for passing information to and from the user interface1110, which is part of the user station 1102, over the network 1106. Itwill be understood that the user station 1102 may be one of a pluralityof user stations in communication with the central processor 1104 overthe network 1106. In one embodiment, the user station 1102 may be a homeor business computer connected to the central processor 1104 through theInternet. In this embodiment, the user sends and receives information tothe central processor 1104 using the browser on the user's computer.

It will be understood that the question optimization module, riskcomputation module and data storage module need not be co-located in asingle processor. For example, in an exemplary alternative embodiment(not shown), the question optimization and risk computation modules maybe located at a user station with the user interface, while the datastorage module is located at or is accessible through a centralprocessor.

Customer information surveys using either of the processing systems1000, 1100 may be conducted with or by an interviewer or otherintermediary who obtains the information from the customer. In theseinstances, the actual questions and other information displayed at theuser station may be hidden from the customer. In some systems, the userstation could include multiple display devices so that some or all ofthe displayed information may be separately displayed to both theinterviewer and the customer or so that one set of information isdisplayed to the customer and a second set of information is displayedto the interviewer. For example, the interviewer's display device mayshow the question set and provided answers along with associated riskcomputations while the customer's display device shows only thequestions and answers.

The processing systems 1000, 1100 may also be used to conduct surveyswithout an interviewer or intermediary. In these instances, thequestions and other information are displayed directly to the customer.

Turning now to FIG. 7, a method 300 of conducting an automated,optimized and compliant customer information survey according to anembodiment of the invention is provided. The method 300 begins at S305and at S310, at least a portion of a current survey question set isdisplayed using a display portion of a user interface. The currentquestion set includes a plurality of questions taken from an overallquestion set containing all possible questions that might need to beasked in order to assure compliance with regulatory criteria. Theoverall question set might also include questions that are needed inorder to meet the needs of the customer, financial institution or both.It can be seen that the current question set is a subset of the overallquestion set. At the start of the survey, the current question set maybe set to equal a basic question set including all of the questions thatall customers must answer. The basic question set may be set to consistof the absolute minimum questions that any customer might be required toanswer. By setting the current question set to be the basic question setat the start of the survey process, a default is established whereby theminimum number of questions will be directed to the customer unless thecurrent question set is modified during the survey.

It will be understood that the overall question set and the basicquestion set may be stored in a data storage portion of the processingsystem from which they may be retrieved for use as needed. The currentquestion set may also be stored and retrieved as needed.

The action of displaying at least a portion of the current question setmay include displaying a single question from the current question setor a plurality of questions from the current question set. In someembodiments, all of the current question set may be displayed orselectively displayable to the user. As used herein, the term “question”means any statement, query, prompt, fill-in space, check-box, etc. thatasks the user to supply a particular piece of information in response.Questions may be displayed in any of a variety of forms. In one simpleapproach, a single question may be displayed requesting the input of asingle answer in response. Alternatively, a plurality of questions maybe displayed for which answers may be entered in sequence orsimultaneously. In a more complex approach, a form having a series ofinput fields may be displayed, each input field having associatedindicia suggesting a question that may be answered by entering data inthe input field. When all the fields are complete, the form is submittedby the user for processing of the answers.

At S320, an answer is received from the user via a user interface inputdevice. It will be understood that the received answer is associatedwith a particular question and may be received by itself or along withanswers to one or more other questions. At S330, the received answer iscompared to an expected answer for the associated question. Aspreviously discussed, an expected answer may be one that has beendetermined to be a likely or most likely response to an associatedquestion. If the received answer is the same as, or substantially thesame as, the expected answer, the method proceeds to S360, where a checkis performed to determine if all the questions of the current questionset have been answered.

As used herein, the term “answer” means any form of data provided orobtained in response to a question. This includes but is not limited toany textual information, choice selection (e.g., by “marking” acheck-box, or making a pull-down selection on a computer screen),numerical entry, or other form of verbal, written or user-input data. Itmay also include electronic data passed from one data processing deviceto another.

If at S330 the received answer is an unexpected answer (i.e., is notsubstantially the same as the expected answer), the method proceeds toS350 where a determination is made whether the current question setshould be updated. As will be discussed below, actions associated withan optional risk factor determination may be conducted at S340. Thedetermination at S350 may be made based on predetermined question setmodification criteria. Such criteria may be associated with particularanswers to particular questions. For example, if an anticipated answerto a particular question is known to be associated with customercharacteristics that will require additional questions over and abovethose of the current question set in order to comply with regulatoryrequirements, it would be desirable for the processing system to updatethe current question set by adding the additional questions.Accordingly, anticipated answers that will trigger a need for additionalquestions may be stored for comparison with received answers. Thedetermination at S350 may then include comparing a received answer withanticipated answers that may trigger the additional questions. If thereceived answer is substantially the same as one of the anticipatedanswers, the associated additional questions drawn from the overallquestion set may be added to the current question set at S352. It willbe understood that under some circumstances, matching an anticipatedanswer could trigger the removal of one or more questions from thecurrent questions set.

If the received answer matches an anticipated triggering answer, thecurrent question set may be revised at S352. The method then proceeds toS360 to determine if there are unanswered questions in the currentquestion set. If the received answer does not match one of theanticipated triggering answers, the current question set remainsunchanged and the method proceeds directly to S360.

It will be understood that the determinations at S330 and S350 may beaccomplished sequentially for multiple answers or may be accomplishedfor multiple answers simultaneously so that the current question set maybe revised only once for a given set of received answers.

If all of the questions of the current question set have been answered,the method proceeds to S370 where the answers may be assembled into acustomer information set and stored. The method then ends at S395. Ifthere are questions in the current question set that have not beenanswered, the method returns to S310 where at least a portion of theupdated current question set is displayed to prompt the user for moreanswers.

The use of expected and anticipated answers in the automated method 300provides the means to streamline the survey to minimize the number ofquestions that a particular customer will be required to answer. Theymay also be used to automatically determine the risk factors associatedwith characteristics that differ from a baseline customer profile. Asnoted above, the automated survey method 300 may include an optionalrisk determination procedure S340. The risk determination procedure S340may be performed for any or all received answers. Thus, the procedureS340 may be performed at any time after an answer has been received.However, it may be particularly efficient to perform the riskdetermination procedure S340 only after an unexpected answer has beenreceived. This is because the risk contribution of an expected answermay already have been accounted for calculating the aggregate customerrisk before the expected answer is received. If, however, an unexpectedanswer is received, any risk factor associated with the unexpectedanswer must be accounted for.

FIG. 8 illustrates an exemplary risk contribution determinationprocedure S340 that may be used in methods of the invention. Theprocedure S340 may comprise a determination S342 of whether arecalculation of the aggregate risk is required by a particular receivedanswer. The determination at S342 may be made based on predeterminedrisk calculation criteria. As with the question set modificationcriteria discussed above, the risk calculation criteria may beassociated with particular answers to particular questions. Inparticular, the risk calculation criteria may include whether thereceived answer matches an anticipated answer for the associatedquestion. For example, if certain anticipated answers for a givenquestion are known to be associated with customer characteristics thathave been correlated to increased risk, a received answer may becompared to these answers to determine if the current aggregate riskshould be recomputed, taking the received answer into account.

Accordingly, anticipated answers that will trigger a need forrecalculation of the aggregate risk associated with a customer may bestored for comparison with received answers. The determination at S342may then include comparing a received answer with anticipated answersthat may trigger a recalculation. If the received answer issubstantially the same as one of the anticipated answers, the aggregaterisk may be recalculated at S344. The recalculation at S344 made includeany of a variety of determinations and calculations depending on themethodology used to calculate the aggregate risk for a customer. Anysuitable risk calculation method in which the effects of a particularcustomer characteristic may be factored is usable in the methods of theinvention. For example, in one illustrative method, a current aggregaterisk for a customer would initially be set at a baseline aggregate riskvalue representing the risk level for a customer who provides onlyexpected answers. An answer specific additive risk factor (which may bepositive or negative) may be associated with each of a predetermined setof anticipated recalculation-triggering answers. Each time a receivedanswer matches an anticipated recalculation-triggering answer, theassociated risk factor may be added to the current aggregate risk. Theaddition of a positive risk factor may indicate a simple additiveincrease in the current aggregate risk associated with the customer. Theaddition of a negative risk factor may indicate a decrease in theaggregate risk.

The simple additive risk approach provides a way of tracking the effectsof answers to questions through the course of a survey. However, thisapproach does not account for the interactive effects of variouscustomer characteristics. For example, a customer may have provided ananswer indicating that a selected financial product of interest is amortgage loan, which differs from the expected answer. The contributionof this answer to the overall risk value for the customer may differdepending on the customer's previously submitted answers relating to,for example, citizenship or income. To overcome such concerns, theaggregate risk calculation at S344 may include computations based, notonly on the received answer triggering the calculation, but on one, someor all previously answered questions. This allows the use ofinterdependent calculations based on predetermined relationships thatcan be associated with anticipated answers. It will be understood thataggregate risk for a customer may still be calculated as the sum ofindividual risk factors calculated for each of a series of customercharacteristics (or associated anticipated answers). Alternatively, theaggregate risk itself may be calculated directly from empiricalcorrelations using risk contribution factors for various characteristicsas input values.

The data processing system used to carry out the methods of theinvention may be configured or programmed to provide as output or todisplay the current aggregate risk at any time during the conduct of asurvey. This can allow interim decisions to be made that can shorten thesurvey process further. For example, any of the methods disclosed hereincan terminate the process based on the determination of a current riskfactor that exceeds a threshold value.

It will be understood that from time-to-time, a financial institutionmay wish to change one or more predetermined risk factor values orchange the form of the calculations used to calculate aggregate risk.Embodiments of the invention provide the capability to make revisions tothe risk calculation model at some later time after a customerinformation set has been established for a particular customer. Thecustomer information set may be configured to include all the answersprovided during a previous survey transaction. The customer informationset may be retrieved from storage and the previously submitted answersused to re-compute the aggregate risk for that customer using the newrisk model.

Anticipated answers may be used for other purposes in addition totriggering changes to the current question set or to the aggregate riskcalculation. For example, certain informational messages or otherinformation be displayed to the user or incorporated into the customerinformation set. For example, citizenship in any of certainpredetermined countries may qualify a customer for a Financial CrimesEnforcement Network (FinCEN) designation. While this may or may notaffect the current question set or the aggregate risk, it may beinformation that should be displayed to an interviewer or stored forlater reference. To accomplish this, the survey methods of the inventionmay include comparing received answers to certain questions toanticipated answers for these questions in order to determine ifpredetermined status flags should be set. For the FinCEN example, theprocessing system may be configured or programmed to compare anyunexpected citizenship answer (for U.S. financial institutions, thislikely to be any answer other than “U.S.”) to a list of FinCENcountries. If the received answer matches a country on the list, aFinCEN flag could be raised.

The methods of the invention may be used to conduct surveys in whichthere are interconnections and dependencies between questions. In someembodiments of the invention, an answer received for a first questionmay be used as a basis for establishing a default answer to a secondquestion. The second question and the default answer may then bedisplayed to the user. Depending on the question and other criteria thatmay be established by the survey manager, the user may be allowed tooverride the default answer by supplying an answer manually. In someinstances, manually overriding the second answer will, in turn, causethe first answer to be changed or will require that the user re-enter ananswer to the first question.

In some embodiments of the invention, automated, interactive, optimizedsurvey methods may involve the use of one or more data entry displayscreens that may be used to prompt a user to enter answers into specificdata fields using a graphical user interface (GUI) or similar device.These display screens may be used to display one, some or all of thequestions in the current question set at any given time in the surveyprocess. As questions are answered by entering data in the appropriatefields, the display screens may changed or replaced to add or subtractquestions. The processing system may be configured or programmed so thatanswers are automatically entered upon movement of a cursor from oneentry field to another. In one alternative to this approach, however,the system may be configured or programmed so that answers are submittedfor processing selectively by the user, either one at a time or ingroups. For example, a “Submit Answers” button may be included on thedisplay screen that when selected by the user causes all previouslyunsubmitted answers to be submitted. In another variation, a particulardisplay screen may be made up of questions that have been groupedtogether because of their relationship to one another. The processingsystem may be configured or programmed so that answers entered into thefields on this page are not submitted until another page is selected,such as by a tab or menu selection.

Whenever answers are submitted for processing by the user, theprocessing system will compare the received answers to the expectedanswers for the transaction being conducted or anticipated. Whenunexpected answers are received, the system determines whether thecurrent question set should be modified and the display screens updatedto reflect the modifications. Questions removed from the currentquestion set may be removed from the screen being displayed to the useror from any screens that are not being displayed but are displayable bythe user. Questions added to the current question set may be added tothe screen being displayed to the user or to any screens that are notbeing displayed but are displayable by the user. Added questions mayalso be provided to the user in the form of a new screen that isdisplayed to the user or is selectively displayable by the user.

The above-described display screens provide a “hide and show” featurewherein only the questions deemed necessary based on previouslysubmitted answers and based on expected answers to the unansweredquestions remaining in the current question set are displayed orselectively displayable by the user. FIGS. 9-13 illustrate the use ofthese display screens in carrying out the methods of the invention. FIG.9 is a screen shot showing a portion of a display screen 410, which maybe displayed to an automated survey user on a GUI. The display screen410 includes question indicia for a plurality of questions, each havingan associated answer field for entering an answer. Questions that mayrequire answers for compliance purposes are indicated by an invertedcarat symbol. The questions shown in display screen 410 may be typicalof questions that would be part of a basic question set that would beanswered by all customers surveyed. The display screen 410 also includesa number of optional information fields and a number of fields that willbe automatically populated as answers are received and processed. Itwill be understood that the portion of the display screen 410 that isshown in FIG. 9 is the portion of the display screen 410 initiallyvisible to the user. The remainder of the display screen 410 is viewableby the user through the use of the scroll bar at the right of thedisplay screen 410. Portions of the display screen 410 may also be“collapsed” to selectively hide all but the title of groups of questionsthat do not need to be viewed at a given time.

FIG. 10 is a second screen shot of the same portion of display screen410 with information entered for a number of questions. Included in theanswers entered was “Guatemala,” which was provided in response to theCountry of Citizenship #1 question (see highlighted line). In thisexample, the received answer “Guatemala” was matched against a set ofanticipated answers including all countries that produce a FinCENdesignation. As a result of a match being found, the default value inthe FinCEN entry for this question was changed from the default value of“No” to “Yes.”

FIG. 11 shows a different portion of display screen 410 that has beenmade visible by collapsing the portions of the screen containingquestions relating to “Identification of Primary Accountholder” and“Referral/Introduction.” The portion of screen 410 shown in FIG. 11comprises a series of unanswered questions relating to income sources ofa customer. FIG. 12 shows a corresponding portion of a modified displayscreen 410A in which answers have been supplied to the sources of wealthquestions through the checking of the “Other” box and the boxes for“Living Trust (Cash),” Living Trust (Non-Cash)” and “InvestmentManagement Account” (highlighted). These unexpected answers caused thecurrent question set to be modified by inserting additional questionsand the display screen 410 to be revised to display these additionalquestions. The additional questions are displayed in the highlightedarea at the bottom of the screen.

FIG. 13 shows another exemplary display screen 510, which is similar tothe display screen 410 discussed above. The display screen 510 of FIG.13, however, includes a graphical representation 520 of the currentaggregate risk level for the customer in addition to a textualdescription 530. These representations may be established based onpredetermined risk intervals established by the financial institution.The graphical risk representation 510 is illustratively shown as a piechart, the darkened area of which represents the relative risk levelassociated with this customer. In the illustrated case, a darkened areaconstituting approximately one third of the pie is associated with a“Low Risk” as stated in the textual risk description 530. It will beunderstood that any convenient graphical representation may be used.Both the graphical and textual representations may be updated at anytime the aggregate risk is recomputed.

Methods of the invention may be implemented through the use of softwarepackages adapted for use with the previously discussed data processingsystems. In the illustrative data processing systems 1000, 1100 of FIGS.5 and 6, the question optimization modules 1020, 1120 may be programmedto carry out the method steps associated with updating a currentquestion set based on expected answer and anticipated answer informationstored in the data storage modules 1040, 1140. The risk determinationmodules 1030, 1130 may be programmed to carry out the method stepsassociated with calculating and recalculating individual riskcontribution values associated with specific customer characteristicsand/or the aggregate risk for a customer using risk calculationcriteria, formulas and empirical data stored in the data storage modules1040, 1140.

The management modules 1050, 1150 may be programmed to allow managementaccess to the various question display criteria and risk determinationcriteria so that the survey tools provided by the software may bereadily adapted to changing conditions or changes in regulatorycriteria. The management modules 1050, 1150 can be used to tailor theappearance, sequence, and grouping of questions and/or display screens.More importantly, the management modules 1050, 1150 may be used toreconfigure the basic rules for question optimization and riskdetermination. The management modules 1050, 1150 may also be used by thesurvey or system manager to structure the interdependence of variousquestions in the survey and the rules for overriding theseinterdependencies and default answers.

The methods of the invention are highly valuable in gathering and usingcustomer information upon initial contact with a customer. The abilityto evaluate customer-associated risk at the front-end of a businessrelationship using a self-optimizing survey provides a unique complianceand risk assessment tool for a financial institution. The methods of theinvention are not, however, confined to circumstances in which thefinancial institution has no prior contact with or information about acustomer. In many instances, a financial institution may already haveinformation about a particular customer from prior dealings with thatcustomer. Such information may be available from previously storedcustomer information sets or otherwise available from databasesaccessible to the survey-conducting processing system. Also, givenminimal information on a customer (e.g., name and social securitynumber), additional customer information may be available from otherpublic sources, such additional information being usable to answer someof the questions in the automated surveys.

Accordingly, some embodiments of the invention may provide for obtaininganswers to survey questions from non-customer sources. Such sources mayinclude any database stored in or accessible to an automated system forcompiling customer information according to methods of the invention.Thus, the automated methods of the invention may include obtaininganswers to survey questions from non-customer sources prior to or duringthe process of obtaining information from a customer. Such answers andtheir associated questions may be selectively displayed to a user duringthe course of the interactive survey. Embodiments of the invention maybe adapted so that a managing authority can determine whether theanswers obtained from non-customer sources may be over-ridden based oncustomer-provided input.

In a particular method according to an embodiment of the invention, theaction of establishing a basic question set, as for example at S350 inFIG. 3, may include a determination of whether certain customerinformation needed for compliance is already available. Upon determiningthat a particular question that would otherwise be included in the basicquestion set may be answered using such information, that question maybe left out of or removed from the basic question set. Similarly, at anytime during an interactive survey, a question of the current optimizedquestion set may be determined to be answerable from non-customersupplied information already available. Such questions may be removedfrom the current optimized question set. Removal of questions fromeither the basic question set or the optimized question set may be madediscretionary to the authority responsible for managing the surveyprogram.

General aspects of possible implementation of the inventive technologywill now be described. Various method and operating system embodimentsof the inventive technology are described above. It will be appreciatedthat the systems of the invention or portions of the systems of theinvention may be in the form of a “processing machine,” such as ageneral purpose computer, for example. As used herein, the term“processing machine” is to be understood to include at least oneprocessor that uses at least one memory. The at least one memory storesa set of instructions. The instructions may be either permanently ortemporarily stored in the memory or memories of the processing machine.The processor executes the instructions that are stored in the memory ormemories in order to process data. The set of instructions may includevarious instructions that perform a particular task or tasks, such asthose tasks described above in the flowcharts. Such a set ofinstructions for performing a particular task may be characterized as aprogram, software program, or simply software.

As noted above, the processing machine executes the instructions thatare stored in the memory or memories to process data. This processing ofdata may be in response to commands by a user or users of the processingmachine, in response to previous processing, in response to a request byanother processing machine and/or any other input, for example.

As previously discussed, the processing machine used to implement theinvention may be a general purpose computer. However, the processingmachine described above may also utilize any of a wide variety of othertechnologies including a special purpose computer, a computer systemincluding a microcomputer, mini-computer or mainframe for example, aprogrammed microprocessor, a micro-controller, a peripheral integratedcircuit element, a CSIC (Customer Specific Integrated Circuit) or ASIC(Application Specific Integrated Circuit) or other integrated circuit, alogic circuit, a digital signal processor, a programmable logic devicesuch as a FPGA, PLD, PLA or PAL, or any other device or arrangement ofdevices that is capable of implementing the steps of the process of theinvention.

It will be understood that in order to practice the method of theinvention as described above, it is not necessary that the processorsand/or the memories of the processing machine be physically located inthe same geographical place. That is, each of the processors and thememories used in the invention may be located in geographically distinctlocations and connected so as to communicate in any suitable manner.Additionally, It will be understood that each of the processor and/orthe memory may be composed of different physical pieces of equipment.Accordingly, it is not necessary that a processor be one single piece ofequipment in one location and that the memory be another single piece ofequipment in another location. That is, it is contemplated that theprocessor may be two pieces of equipment in two different physicallocations. The two distinct pieces of equipment may be connected in anysuitable manner. Additionally, the memory may include two or moreportions of memory in two or more physical locations.

To explain further, processing as described above is performed byvarious components and various memories. However, It will be understoodthat the processing performed by two distinct components as describedabove may, in accordance with a further embodiment of the invention, beperformed by a single component. Further, the processing performed byone distinct component as described above may be performed by twodistinct components. In a similar manner, the memory storage performedby two distinct memory portions as described above may, in accordancewith a further embodiment of the invention, be performed by a singlememory portion. Further, the memory storage performed by one distinctmemory portion as described above may be performed by two memoryportions.

Further, various technologies may be used to provide communicationbetween the various processors and/or memories, as well as to allow theprocessors and/or the memories of the invention to communicate with anyother entity; i.e., so as to obtain further instructions or to accessand use remote memory stores, for example. Such technologies used toprovide such communication might include a network, the Internet,Intranet, Extranet, LAN, an Ethernet, or any client server system thatprovides communication, for example. Such communications technologiesmay use any suitable protocol such as TCP/IP, UDP, or OSI, for example.

As described above, a set of instructions is used in the processing ofthe invention. The set of instructions may be in the form of a programor software. The software may be in the form of system software orapplication software, for example. The software might also be in theform of a collection of separate programs, a program module within alarger program, or a portion of a program module, for example Thesoftware used might also include modular programming in the form ofobject oriented programming. The software tells the processing machinewhat to do with the data being processed.

It will be understood that the instructions or set of instructions usedin the implementation and operation of the invention may be in asuitable form such that the processing machine may read theinstructions. For example, the instructions that form a program may bein the form of a suitable programming language, which is converted tomachine language or object code to allow the processor or processors toread the instructions. That is, written lines of programming code orsource code, in a particular programming language, are converted tomachine language using a compiler, assembler or interpreter. The machinelanguage is binary coded machine instructions that are specific to aparticular type of processing machine, i.e., to a particular type ofcomputer, for example. The computer understands the machine language.

Any suitable programming language may be used in accordance with thevarious embodiments of the invention. Illustratively, the programminglanguage used may include assembly language, Ada, APL, Basic, C, C++,COBOL, dBase, Forth, Fortran, Java, Modula-2, Pascal, Prolog, REXX,Visual Basic, and/or JavaScript, for example. Further, it is notnecessary that a single type of instructions or single programminglanguage be utilized in conjunction with the operation of the system andmethod of the invention. Rather, any number of different programminglanguages may be utilized as is necessary or desirable.

Also, the instructions and/or data used in the practice of the inventionmay utilize any compression or encryption technique or algorithm, as maybe desired. An encryption module might be used to encrypt data. Further,files or other data may be decrypted using a suitable decryption module,for example.

As described above, the invention may illustratively be embodied in theform of a processing machine, including a computer or computer system,for example, that includes at least one memory. It is to be appreciatedthat the set of instructions, i.e., the software for example, thatenables the computer operating system to perform the operationsdescribed above may be contained on any of a wide variety of media ormedium, as desired. Further, the data that is processed by the set ofinstructions might also be contained on any of a wide variety of mediaor medium. That is, the particular medium, i.e., the memory in theprocessing machine, utilized to hold the set of instructions and/or thedata used in the invention may take on any of a variety of physicalforms or transmissions, for example. Illustratively, the medium may bein the form of paper, paper transparencies, a compact disk, a DVD, anintegrated circuit, a hard disk, a floppy disk, an optical disk, amagnetic tape, a RAM, a ROM, a PROM, a EPROM, a wire, a cable, a fiber,communications channel, a satellite transmissions or other remotetransmission, as well as any other medium or source of data that may beread by the processors of the invention.

Further, the memory or memories used in the processing machine thatimplements the invention may be in any of a wide variety of forms toallow the memory to hold instructions, data, or other information, as isdesired. Thus, the memory might be in the form of a database to holddata. The database might use any desired arrangement of files such as aflat file arrangement or a relational database arrangement, for example.

In the system and method of the invention, a variety of “userinterfaces” may be utilized to allow a user to interface with theprocessing machine or machines that are used to implement the invention.As used herein, a user interface includes any hardware, software, orcombination of hardware and software used by the processing machine thatallows a user to interact with the processing machine. A user interfacemay be in the form of a dialogue screen for example. A user interfacemay also include any of a mouse, touch screen, keyboard, voice reader,voice recognizer, dialogue screen, menu box, list, checkbox, toggleswitch, a pushbutton or any other device that allows a user to receiveinformation regarding the operation of the processing machine as itprocesses a set of instructions and/or provide the processing machinewith information. Accordingly, the user interface is any device thatprovides communication between a user and a processing machine. Theinformation provided by the user to the processing machine through theuser interface may be in the form of a command, a selection of data, orsome other input, for example.

As discussed above, a user interface is utilized by the processingmachine that performs a set of instructions such that the processingmachine processes data for a user. The user interface is typically usedby the processing machine for interacting with a user either to conveyinformation or receive information from the user. However, it should beappreciated that in accordance with some embodiments of the system andmethod of the invention, it is not necessary that a human user actuallyinteract with a user interface used by the processing machine of theinvention. Rather, it is contemplated that the user interface of theinvention might interact, i.e., convey and receive information, withanother processing machine, rather than a human user. Accordingly, theother processing machine might be characterized as a user. For example,in the survey methods of the invention, answers to survey questions maybe obtained from a another processing machine through the use ofautomated database searching. Further, it is contemplated that a userinterface utilized in the system and method of the invention mayinteract partially with another processing machine or processingmachines, while also interacting partially with a human user.

It will be readily understood by those persons skilled in the art thatthe present invention is susceptible to broad utility and application.Many embodiments and adaptations of the present invention other thanthose herein described, as well as many variations, modifications andequivalent arrangements, will be apparent from or reasonably suggestedby the present invention and foregoing description thereof, withoutdeparting from the substance or scope of the invention.

While the foregoing illustrates and describes exemplary embodiments ofthis invention, it is to be understood that the invention is not limitedto the construction disclosed herein. The invention can be embodied inother specific forms without departing from the spirit or essentialattributes.

1. A computer-implemented method of compiling a customer information setthat complies with regulatory criteria in the minimum number ofsequenced questions, the method comprising: providing an overallquestion set having a plurality of questions; determining from theoverall question set a basic question set asked of all users, whereineach question of the basic question set is associated with an expectedanswer and wherein the basic question set comprises the minimum numberof sequenced questions the answers to which would be sufficient to meetthe regulatory criteria if no unexpected answers are given; providingpredetermined sequenced criteria for supplementing the basic questionset with supplemental additional questions from the overall question setwithin the sequence of the basic question set, wherein the criteria arestructured to minimize the number of remaining questions that must beanswered in order to comply with the regulatory criteria; conducting anoptimized interactive customer survey, comprising: presenting eachquestion of the basic question set to a user; receiving from the user ananswer to each basic question; determining if the received answer is theexpected answer for the question asked; upon a determination that thereceived answer is the expected answer, continuing in the basic questionset sequence to the next question in the basic question set; upon adetermination that the received answer is not the expected answer,presenting supplemental additional questions based on the predeterminedsequenced criteria for supplementing the basic question set andreturning to the sequence of the basic question set once the userprovides the expected answer to the supplemental additional questions;repeating the preceding steps until all basic questions and requiredsupplemental additional questions have been asked and answered; andinforming the customer of completion of the survey once the customerprovides answers to the minimum number of questions needed to complywith the regulatory criteria; wherein the preceding steps areimplemented by a computer, comprising at least a computer processor. 2.A method according to claim 1, wherein the action of conducting anoptimized interactive customer survey includes: displaying to a user theat least one question of the basic question set; receiving from the useran answer to the at least one question of the basic question set;determining whether the received answer differs from the expected answerassociated with the at least one question of the basic question set;responsive to a determination that the answer differs from the expectedanswer associated with the at least one question of the basic questionset, establishing an updated question set using the overall questionset, the basic question set and the criteria for modifying the basicquestion set; and displaying to the user at least one question from theupdated question set.
 3. A method according to claim 1, furthercomprising: constructing a customer information set using answersreceived during the optimized interactive customer survey; and storingthe customer information set.
 4. A method according to claim 1, whereinthe basic question set includes a plurality of questions from theoverall question set and wherein the action of conducting an optimizedinteractive customer survey includes: displaying a first displayquestion set consisting of a plurality of questions from the basicquestion set including at least one question having an associatedexpected answer; receiving from the user an answer to the at least onequestion having an associated expected answer; determining whether thereceived answer differs from the expected answer associated with the atleast one question having an associated expected answer; and responsiveto a determination that the answer differs from the expected answer,establishing an updated question set using the overall question set, thebasic question set and the criteria for modifying the basic question setand displaying a second display question set consisting of a pluralityof questions from the updated question set.
 5. A method according toclaim 1 further comprising: associating an anticipated answer set withat least one of the plurality of supplemental additional questions, theanticipated answer set comprising at least one anticipated answer; andresponsive to receiving during the optimized interactive customer surveyan answer to the at least one of the plurality of supplementaladditional questions that matches one of the at least one anticipatedanswer, determining a risk contribution factor to be associated with thereceived answer.
 6. A method according to claim 5 wherein the riskcontribution factor is determined from a predetermined risk contributionfactor value associated with the at least one anticipated answer.
 7. Amethod according to claim 6 wherein the risk contribution factor isdetermined based on a risk factor calculation that uses a firstpredetermined risk factor value, the first predetermined risk factorvalue being associated with the at least one anticipated answer.
 8. Amethod according to claim 7 wherein the risk factor calculation alsouses a second predetermined risk factor value, the second predeterminedrisk factor value being associated with a second anticipated answer thathas been matched by a received answer.
 9. A method according to claim 1further comprising: associating an anticipated answer set with at leastone of the plurality of questions, the anticipated answer set comprisingat least one anticipated answer; and responsive to receiving during theoptimized interactive customer survey an answer to the at least one ofthe plurality of questions that matches one of the at least oneanticipated answer, determining an aggregate risk value.
 10. A methodaccording to claim 9 wherein the risk contribution factor is determinedfrom a predetermined risk contribution factor value associated with theat least one anticipated answer.
 11. A method according to claim 10wherein the risk contribution factor is determined based on a riskfactor calculation that uses a first predetermined risk factor value,the first predetermined risk factor value being associated with the atleast one anticipated answer.
 12. A method according to claim 11 whereinthe risk factor calculation also uses a second predetermined risk factorvalue, the second predetermined risk factor value being associated witha second anticipated answer that has been matched by a received answer.13. A method according to claim 1, wherein the action of conducting anoptimized interactive customer survey is carried out as part of afront-end customer identification procedure.
 14. A method according toclaim 1 further comprising: determining for at least one basic questionwhether an answer to the at least one basic question may be determinedfrom non-customer-supplied information; and responsive to adetermination that an answer to the at least one basic question may bedetermined from non-customer-supplied information, removing the at leastone basic question from the basic question set.
 15. Acomputer-implemented method of compiling a customer information set thatcomplies with regulatory criteria in the minimum number of sequencedquestions, the method comprising: displaying to a user at least onequestion asked of all users having an associated single expected answer,the at least one question having been selected from an overall questionset comprising all possible questions for which answers may be requiredin order to comply with the regulatory criteria, wherein the at leastone question comprises the minimum number of sequenced questions theanswers to which would be sufficient to meet the regulatory criteria ifno unexpected answers are given; receiving an answer to a selected oneof the at least one question, the answer being reflective of informationrelating to a customer; determining whether the answer differs from thesingle expected answer associated with the selected question; responsiveto a determination that the answer differs from the single expectedanswer associated with the selected question, establishing an optimumquestion set of the at least one question and at least one supplementalquestion from the overall question set, the optimum question set havinga minimum number of sequenced questions the answers to which would besufficient to meet the regulatory criteria based on the answer to theselected question if no additional unexpected answers are given;displaying to the user at least one question from the optimum questionset, wherein the at least one supplemental question is displayed to theuser within the sequence of the at least one question; and wherein thepreceding steps are implemented by a computer, comprising at least acomputer processor.
 16. A method according to claim 15 furthercomprising: receiving an answer to a selected one of the at least onequestion from the optimum question set; determining whether the selectedone of the at least one question from the optimum question set has anassociated expected answer; responsive to a determination that theselected one of the at least one question from the optimum question sethas an expected answer, determining if the answer to the selected one ofthe at least one question from the optimum question set differs from theexpected answer for the selected one of the at least one question fromthe optimum question; and responsive to a determination that the answerto a selected one of the at least one question from the optimum questionset differs from the expected answer for the selected one of the atleast one question from the optimum question, revising the optimumquestion set so that the optimum question set has a minimum number ofquestions required for compliance with the regulatory criteria given theanswer to the selected one of the at least one question from the optimumquestion set.
 17. A method according to claim 16 wherein the actions ofclaim 16 are repeated until an answer has been received for eachquestion in the optimum question set.
 18. A method according to claim 15further comprising: displaying to a user at least one question from theoverall question set having an associated first anticipated answer;receiving an answer to the at least one question from the overallquestion set having an associated first anticipated answer, the receivedanswer being reflective of information relating to the customer;determining whether the received answer to the at least one questionfrom the overall question set differs from the first anticipated answer;and responsive to a determination that the received answer differs fromthe first anticipated answer, determining a risk contribution factor tobe associated with the received answer.
 19. A method according to claim18 wherein the risk contribution factor is determined from apredetermined risk contribution factor value associated with the firstanticipated answer.
 20. A method according to claim 18 wherein the riskcontribution factor is determined based on a risk factor calculationthat uses a first predetermined risk factor value, the firstpredetermined risk factor value being associated with the firstanticipated answer.
 21. A method according to claim 20 wherein the riskfactor calculation also uses a second predetermined risk factor value,the second predetermined risk factor value being associated with asecond anticipated answer that has been matched by a previously receivedanswer.
 22. A method according to claim 15 further comprising:displaying to a user at least one question from the overall question sethaving an associated anticipated answer; receiving an answer to the atleast one question from the overall question set having an associatedanticipated answer, the answer being reflective of information relatingto the customer; determining whether the answer to the at least onequestion from the overall question set differs from the expected answerassociated with the at least one question from the overall question set;and responsive to a determination that the received answer differs fromthe expected answer associated with the at least one question from theoverall question set, determining an aggregate risk value for thecustomer.
 23. A method according to claim 22 wherein the riskcontribution factor is determined from a predetermined risk contributionfactor value associated with the first anticipated answer.
 24. A methodaccording to claim 22 wherein the risk contribution factor is determinedbased on a risk factor calculation that uses a first predetermined riskfactor value, the first predetermined risk factor value being associatedwith the first anticipated answer.
 25. A method according to claim 24wherein the risk factor calculation also uses a second predeterminedrisk factor value, the second predetermined risk factor value beingassociated with a second anticipated answer that has been matched by apreviously received answer.
 26. A method according to claim 15, whereinthe actions of displaying to a user at least one question having anassociated expected answer, receiving an answer to a selected one of theat least one question, determining whether the answer differs from theexpected answer, responsive to a determination that the answer differsfrom the expected answer, establishing an optimum question set, anddisplaying to the user at least one question from the optimum questionset are carried out as part of a front-end customer identificationprocedure.
 27. A method according to claim 15 further comprising:determining for at least one optimum set question whether an answer tothe at least one optimum set question may be determined fromnon-customer-supplied information; and responsive to a determinationthat an answer to the at least one optimum set question may bedetermined from non-customer-supplied information, removing the at leastone optimum set question from the optimum question set.
 28. Acomputer-implemented method of compiling a customer information set thatcomplies with regulatory criteria in the minimum number of sequencedquestions, the method comprising: displaying to a user at least onequestion asked of all users and having an associated single expectedanswer, the at least one question having been selected from an optimumsubset of an overall question pool comprising all possible questions forwhich answers may be required in order to comply with the regulatorycriteria, the optimum subset including only an optimized set ofsequenced questions, wherein the optimized set of sequenced questionscomprises the minimum number of questions the answers to which would besufficient to meet the regulatory criteria if no unexpected answers arereceived; receiving an answer to a selected one of the at least onequestion, the answer providing information relating to a customer;adding the information to a customer information set for the customer;comparing the answer to the single expected answer associated with theselected question to determine if the answer is an unexpected answer;responsive to a determination that the answer is an unexpected answer,revising the optimum subset to include supplemental questions from theoverall question pool, wherein the optimized set of sequenced questionsand supplemental questions comprises the minimum number of questions theanswers to which would be sufficient to meet the regulatory criteria ifno further unexpected answers are received; displaying to the user atleast one question from the revised optimum subset, wherein thesupplemental questions are displayed to the user within the sequence ofthe optimum subset; and wherein the preceding steps are implemented by acomputer, comprising at least a computer processor.
 29. A methodaccording to claim 28 further comprising: receiving an answer to aselected one of the at least one question from the optimum subset;determining whether the selected one of the at least one question fromthe optimum subset has an associated expected answer; responsive to adetermination that the selected one of the at least one question fromthe optimum subset has an expected answer, comparing the answer for theselected one of the at least one question from the optimum subset to theexpected answer associated with the selected one of the at least onequestion from the optimum subset to determine if the answer is anunexpected answer; and responsive to a determination that the answer tothe selected one of the at least one question from the optimum subset isan unexpected answer, revising the optimum subset to include onlyanother re-optimized set of questions, the answers to which would besufficient to meet the regulatory criteria if no further unexpectedanswers are received.
 30. A method according to claim 29 wherein theactions of claim 30 are repeated until an answer has been received foreach question in the optimum question set.
 31. A method according toclaim 28 further comprising: displaying to a user at least one questionfrom the overall question set having an associated first anticipatedanswer; receiving an answer to the at least one question from theoverall question set having an associated first anticipated answer, thereceived answer being reflective of information relating to thecustomer; determining whether the received answer to the at least onequestion from the overall question set differs from the firstanticipated answer; and responsive to a determination that the receivedanswer differs from the first anticipated answer, determining a riskcontribution factor to be associated with the received answer.
 32. Amethod according to claim 31 wherein the risk contribution factor isdetermined from a predetermined risk contribution factor valueassociated with the first anticipated answer.
 33. A method according toclaim 31 wherein the risk contribution factor is determined based on arisk factor calculation that uses a first predetermined risk factorvalue, the first predetermined risk factor value being associated withthe first anticipated answer.
 34. A method according to claim 33 whereinthe risk factor calculation also uses a second predetermined risk factorvalue, the second predetermined risk factor value being associated witha second anticipated answer that has been matched by a previouslyreceived answer.
 35. A method according to claim 28 further comprising:displaying to a user at least one question from the overall question sethaving an associated anticipated answer; receiving an answer to the atleast one question from the overall question set having an associatedanticipated answer, the answer being reflective of information relatingto the customer; determining whether the answer to the at least onequestion from the overall question set differs from the expected answerassociated with the at least one question from the overall question set;and responsive to a determination that the received answer differs fromthe expected answer associated with the at least one question from theoverall question set, determining an aggregate risk value for thecustomer.
 36. A method according to claim 35 wherein the riskcontribution factor is determined from a predetermined risk contributionfactor value associated with the first anticipated answer.
 37. A methodaccording to claim 35 wherein the risk contribution factor is determinedbased on a risk factor calculation that uses a first predetermined riskfactor value, the first predetermined risk factor value being associatedwith the first anticipated answer.
 38. A method according to claim 37wherein the risk factor calculation also uses a second predeterminedrisk factor value, the second predetermined risk factor value beingassociated with a second anticipated answer that has been matched by apreviously received answer.